Justia Transportation Law Opinion Summaries

Deborah Bradshaw and Chrystal Antao sued American Airlines and Mesa Airlines, alleging injuries and damages from the airlines' negligent handling of an in-flight emergency. During a June 2020 flight, the aircraft experienced a malfunction that led to a loss of cabin pressure, requiring an emergency descent. The plaintiffs claimed the pilot failed to properly inform passengers of the threat and descended too rapidly, while American Airlines failed to provide medical personnel upon landing.The case was initially filed in the District Court of Tulsa County, Oklahoma, and later removed to the United States District Court for the Northern District of Oklahoma on diversity grounds. The district court granted summary judgment in favor of the airlines, concluding that federal law preempted Oklahoma's common-carrier standard of care in aviation safety. The court allowed the plaintiffs to pursue a state negligence claim using the federal "reckless-or-careless manner" standard but found no evidence that the airlines violated this standard.The United States Court of Appeals for the Tenth Circuit reviewed the case. The court affirmed the district court's decision, holding that the Federal Aviation Act and related regulations preempt state law in the field of aviation safety. The court agreed that the federal "careless or reckless manner" standard of care applies, preempting Oklahoma's common-carrier standard. The court found no genuine issue of material fact regarding a violation of federal regulations by the airlines and upheld the summary judgment in favor of the defendants. View "Bradshaw v. American Airlines" on Justia Law

The Vermont Agency of Transportation (AOT) proposed a project to reconstruct the interchange between Interstate 89 and U.S. Routes 2 and 7 in Colchester, Vermont, into a Diverging Diamond Interchange (DDI). Timberlake Associates, LLP, the landowner of a gas station at the southeast corner of the interchange, contested the necessity of the land takings required for the project. Timberlake argued that AOT did not fulfill its pre-suit obligation to negotiate and that the trial court erred in its determination of necessity.The Superior Court, Chittenden Unit, Civil Division, held a four-day evidentiary hearing and concluded that Timberlake failed to demonstrate bad faith or abuse of discretion by AOT. The court found that AOT had satisfied its burden of demonstrating the necessity of taking Timberlake’s property to the extent proposed. Timberlake appealed the decision, arguing that AOT did not adequately consider the statutory factors of necessity and failed to negotiate in good faith.The Vermont Supreme Court reviewed the case and affirmed the lower court’s decision. The Court found that AOT presented sufficient evidence showing it considered the statutory factors, including the adequacy of other property and locations, the effect on the landowner’s convenience, and the environmental impacts. The Court also determined that AOT’s selection of the DDI design was justified based on its superior performance in increasing capacity, reducing congestion, and improving safety compared to other alternatives. Additionally, the Court concluded that AOT made reasonable efforts to negotiate with Timberlake before filing suit, as required by statute.The Vermont Supreme Court held that the trial court acted within its discretion in determining the necessity of the takings and that AOT fulfilled its pre-suit obligation to negotiate. The decision of the lower court was affirmed. View "Agency of Transportation v. Timberlake Associates, LLC" on Justia Law

Donald Blazer was involved in a vehicle accident and voluntarily submitted to a preliminary breath test (PBT), which showed a blood alcohol content of .102 percent. However, he refused to submit to a blood draw. The South Dakota Department of Public Safety (Department) notified Blazer of its intent to disqualify his commercial driver’s license (CDL) for life, citing this refusal as a second violation of SDCL 32-12A-36, with the first being a 2014 DUI conviction. Blazer requested an administrative hearing, and the Department affirmed the disqualification of his CDL for life.Blazer appealed to the circuit court, which reversed the Department’s decision. The circuit court concluded that Blazer’s voluntary submission to the breath test constituted a submission to a chemical analysis, meaning his refusal to submit to the blood draw could not result in the disqualification of his CDL. The Department then appealed to the South Dakota Supreme Court.The South Dakota Supreme Court reviewed the case and reversed the circuit court’s decision. The Court held that under SDCL 32-23-1.2, a preliminary breath test (PBT) is permitted and may be required in addition to a chemical test. The Court determined that Blazer’s refusal to submit to the blood draw constituted a refusal to submit to a chemical analysis as required by SDCL 32-12A-46. This refusal was a second violation under SDCL 32-12A-36, justifying the disqualification of Blazer’s CDL for life under SDCL 32-12A-37. The Court emphasized that a PBT is a preliminary test and does not fulfill the requirement for a chemical analysis under the implied consent laws. View "Blazer v. Department of Public Safety" on Justia Law

Wisconsin Central Ltd. and Soo Line Railroad Company are in dispute over the location for exchanging rail traffic in the Chicago area. Wisconsin Central prefers the Belt Railway yard near Chicago, while Soo Line prefers the Spaulding yard near Bartlett, 35 miles away. The Surface Transportation Board initially ruled against Wisconsin Central, stating that it could not use Belt Railway's yard because it did not own it outright, despite having a contractual right to use it. The Seventh Circuit Court of Appeals remanded the case, clarifying that a railroad could have the power to designate facilities by contract as well as by ownership.Upon remand, the Surface Transportation Board held that the Belt Railway yard was not a reasonable location for the exchange. The Board found that both locations could cause congestion but concluded that it was unreasonable for Wisconsin Central to insist that Soo Line bear the costs of moving cars to Chicago and the fees charged by Belt Railway. Additionally, the Board emphasized the importance of negotiation and agreement in selecting exchange locations, rather than allowing one party to unilaterally change the location.The United States Court of Appeals for the Seventh Circuit reviewed the Board's decision. The court held that the Board's interpretation of "reasonable" was within its discretion and that considering costs as part of reasonableness was appropriate. The court also noted that Wisconsin Central did not preserve its argument regarding substantial evidence for review. Consequently, the court found that the Board's decision was neither arbitrary nor capricious and did not embody a legal error. The petition for review was denied. View "Wisconsin Central Ltd. v. Surface Transportation Board" on Justia Law

Ali Bahreman, a flight attendant for Allegiant Air, challenged the Collective Bargaining Agreement (CBA) between Allegiant and the Transport Workers Union (Union). The CBA required employees to either pay union dues or agency fees to maintain seniority-based bidding privileges for work schedules. Bahreman chose not to pay any fees and subsequently lost his bidding privileges. He argued that this arrangement violated the Railway Labor Act (RLA) by coercing employees to join the Union, deviating from the employment-termination remedy, and breaching the Union's duty of fair representation.The United States District Court for the District of Nevada granted summary judgment in favor of Allegiant and the Union. The court found that the CBA did not violate the RLA's anti-coercion provision, as it did not induce employees to join the Union. The court also held that the RLA does not prohibit collective bargaining agreements with terms other than those explicitly permitted by the Act. Additionally, the court determined that the Union did not breach its duty of fair representation, as it enforced the CBA equally among all members of the bargaining unit.The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit held that the RLA does not prohibit a collective bargaining agreement that conditions seniority-based bidding privileges on the payment of union dues or agency fees. The court found that the CBA did not induce union membership, as it treated union members and nonmembers alike regarding payment requirements. The court also concluded that the CBA's terms were permissible under the RLA and that the Union did not act arbitrarily, discriminatorily, or in bad faith in enforcing the agreement. View "Bahreman v. Allegiant Air, LLC" on Justia Law

In 2016, Rhode Island enacted the RhodeWorks Act, which imposed tolls on tractor-trailers crossing thirteen bridges within the state. The toll revenue was intended for the replacement, reconstruction, operation, and maintenance of these bridges. The tolls were subject to three statutory caps: a truck could not pay more than once in each direction, more than $40 per day, or more than $20 for a single through trip from Connecticut to Massachusetts. The American Trucking Associations and several trucking companies challenged the tolls, arguing they violated the dormant Commerce Clause by discriminating against interstate commerce and failing to fairly approximate use of the bridges.The U.S. District Court for the District of Rhode Island permanently enjoined the tolls, finding that they discriminated against interstate commerce and did not fairly approximate use. The court concluded that the tolls' application solely to tractor-trailers and the statutory caps each violated the dormant Commerce Clause.The United States Court of Appeals for the First Circuit reviewed the case. The court agreed that the statutory caps on tolls were unconstitutional because they disproportionately benefited in-state over out-of-state tractor-trailers, thus discriminating against interstate commerce. However, the court held that the tolls' application solely to tractor-trailers did not violate the fair-approximation test, as it was not wholly unreasonable for Rhode Island to rely on studies showing that tractor-trailers caused the most damage to the bridges.The First Circuit concluded that the unconstitutional caps were severable from the rest of the statute. Therefore, the court affirmed the district court's judgment in part, reversed it in part, and remanded the case for the entry of judgment consistent with its opinion. View "American Trucking Associations, Inc. v. Rhode Island Turnpike and Bridge Authority" on Justia Law

Sky Moore rented a car from Budget Car and Truck Rental of Las Vegas, owned by Malco Enterprises of Nevada, Inc. Sky named Daniel Moore as an additional driver, who later rear-ended Alelign Woldeyohannes while intoxicated. Alelign sued Daniel for negligence and Malco for negligent entrustment. Daniel did not respond, resulting in a default judgment against him. The case proceeded to arbitration, where Alelign was awarded $32,680.26. Malco requested a trial de novo, leading to a short trial where the judge entered a default judgment against Daniel for $37,886.82.Alelign moved to apply the default judgment against Malco under NRS 482.305(1), which holds short-term lessors liable for damages if they fail to provide minimum insurance coverage. Malco opposed, arguing that NRS 482.305 is preempted by the Graves Amendment, which prohibits states from holding vehicle lessors vicariously liable without negligence or wrongdoing. The short trial judge granted Alelign’s motion, and the district court affirmed, concluding that NRS 482.305 is a financial responsibility law preserved by the Graves Amendment’s savings clause.The Supreme Court of Nevada reviewed the case and affirmed the district court’s judgment. The court held that NRS 482.305 is not preempted by the Graves Amendment because it is a financial responsibility law preserved by the savings clause under 49 U.S.C. § 30106(b). The court emphasized that NRS 482.305 imposes a legal requirement for lessors to provide minimum coverage, rather than a mere financial inducement, and does not impose strict vicarious liability on lessors. View "Malco Enterprises of Nevada, Inc. vs. Woldeyohannes" on Justia Law

Angelo Brock, an independent distributor for Flowers Baking Co. of Denver, LLC, filed a class-action lawsuit alleging wage and hour violations under the Fair Labor Standards Act and Colorado labor law. Brock claimed that Flowers misclassified its delivery drivers as independent contractors to avoid paying proper wages. Flowers moved to compel arbitration based on an Arbitration Agreement within the Distributor Agreement between Brock and Flowers. The district court denied the motion, leading to this appeal.The United States District Court for the District of Colorado found that Brock fell within the "transportation workers exemption" under § 1 of the Federal Arbitration Act (FAA), which exempts certain transportation workers from arbitration. The court concluded that Brock's class of workers, who deliver Flowers goods intrastate, are engaged in interstate commerce because they play a direct and necessary role in the flow of goods across state lines. The court also determined that the Arbitration Agreement did not allow for arbitration under Colorado law, as it was inconsistent with the FAA.The United States Court of Appeals for the Tenth Circuit affirmed the district court's decision. The Tenth Circuit agreed that Brock's class of workers is engaged in interstate commerce, as their intrastate deliveries are part of a continuous interstate journey of goods. The court found that Flowers retains significant control over Brock's operations, indicating that the goods' delivery to retail stores is the final leg of an interstate route. The court declined to review Flowers's argument that the Distributor Agreement is not a contract of employment, as it was not raised in the lower court. Additionally, the court determined it lacked jurisdiction to review the district court's denial of arbitration under Colorado law. View "Brock v. Flowers Foods" on Justia Law

Eason Propane, LLC, purchased a new Freightliner propane delivery truck, which caught fire due to Empire Truck Sales, LLC's negligence during repairs. The fire caused significant damage to the truck, leading to extensive business losses for Eason Propane. Eason Propane sued Empire, seeking damages for the truck's diminished value, repair costs, lost profits, and other consequential damages.The case was tried in the Lamar County Circuit Court, where the jury found Empire liable and awarded Eason Propane $263,443.39 in damages. Empire moved for a new trial on damages or a remittitur, arguing that the jury's award was against the overwhelming weight of the evidence. The trial court denied Empire's motion, leading to this appeal.The Supreme Court of Mississippi reviewed the case and affirmed the trial court's decision. The court held that the jury's damages award was not manifestly unjust or so excessive as to shock the conscience. The court found that the evidence presented at trial supported the jury's findings, including the testimony of Eason Propane's experts regarding the truck's diminished value and lost profits. The court emphasized that it was within the jury's purview to weigh the credibility of the competing testimonies and evidence.The court concluded that the trial court did not abuse its discretion in denying Empire's motion for a new trial or remittitur. The jury's award of $112,698.46 for the truck's diminished value, $24,744.93 for repair costs, $120,000 for lost profits, and $6,000 for other consequential damages was affirmed. View "Stribling Equipment, LLC v. Eason Propane, LLC" on Justia Law

In August 2014, a train operated by BNSF Railway Company collided with a pickup truck driven by Paul Watson at a railroad crossing in Pawnee County, Oklahoma. Watson, who was not wearing a seatbelt, died instantly, while his wife Terri and their minor child, both belted, survived with injuries. Terri Watson, on behalf of herself, her child, and as a representative of her deceased husband's estate, filed a wrongful death and personal injury lawsuit against BNSF, alleging negligent maintenance of the crossing and failure to install adequate safety features.The case went to trial, and after three weeks of testimony and evidence, the jury found in favor of BNSF on all claims. The plaintiffs' motion for a new trial was denied by the trial court. On appeal, the Court of Civil Appeals, Division IV, found prejudicial errors in the jury instructions, specifically noting that the instructions were biased in favor of BNSF and required an excessive degree of care from Watson. The appellate court reversed the trial court's decision and remanded the case for a new trial.The Supreme Court of the State of Oklahoma reviewed the case on certiorari. The court found that the jury instructions, when considered as a whole, were not so prejudicial as to mislead the jury. The court noted that the instructions accurately reflected Oklahoma law and did not impose a higher standard of care on Watson than required. Consequently, the Supreme Court vacated the opinion of the Court of Civil Appeals, affirmed the trial court's judgment, and reinstated the jury's verdict in favor of BNSF. The case was remanded for further proceedings consistent with this opinion. View "WATSON v. BNSF RAILWAY COMPANY" on Justia Law